Water

Am I a PWS?

Canyon Springs Engineering (CSE) works with small Public Water Systems (PWS). Our definition of "small" is serving water to a population of 25 to 5,000 persons.

This four word question is always the first question to address.

Public Water System Temporary pump for pump test

From the TCEQ web page titled: "Am I a Public Water System"?

If you supply water to other people, even if it's bottled, you might be a public water system (PWS). Find out if you are a PWS and, if so, what requirements you must meet.

Definition of a Public Water System

If you provide water to the public, you may be a public water system (PWS). State and federal regulations define PWSs [30 TAC §290.38(71), Fed Ref] A PWS provides potable water for the public’s use. A system must be a certain size to be considered public: it must have at least 15 service connections
OR
serve at least 25 individuals for at least 60 days out of the year. This includes folks that live in houses served by a system, but can also include people that don’t live there. For instance, people served could include employees, customers, or students.

PWS Exercise for Clients

When we are speaking with a potential PWS client, we like to walk them through the following exercise. 

Pick the 60 busiest days of the year.
Are there 25 or more persons (employees, tenants, customers, visitors, students, etc.) at the location during each of those 60 days? (See Notes below.)
If the answer is yes, you meet the definition of a PWS and should have a PWS approval to operate.

On the surface, this sounds like a straightforward and simple evaluation... and it is if one understands the various definitions.

Understandably, many small operators don't "speak the language" of PWS rules.

Contact Canyon Springs Engineering to help interpret the TCEQ PWS rules and how they might, or might not, apply to your specific scenario.

Notes:

You must assume 100% occupancy + employees.
Time on site is not a factor in this evaluation. A person there for 24 minutes is counted the same as a person there for 24 hrs.
Visitors are typically included, though there are some scenarios where you can exclude them.

When you visit the TCEQ page linked above, do not get confused by the three types of public water systems. When evaluating the "Am I a PWS" question, you only look at the PWS definition. The definitions for the three types of systems can be confusing and often times, misinterpreted. If you meet the definition of a PWS, you will be categorized as one of the three types, whether you think they are applicable or not.

Bonus: This example came from TCEQ personnel:

If you have an event venue and have 4,000 persons present every Saturday, that is only 52 days and are not a PWS. (52 less than 60 days)
If you have 25 persons every Saturday and Sunday, that is 104 days with 25 persons and therefore would be a PWS. (104 greater than 60 days)

If you are a/an...

Owner/Operator
(or should be an owner/operator)

After reading “Am I a PWS” above and you think you might be a PWS, give us a call. We can help evaluate your specific scenario.

Examples:

RV campgrounds
Tiny/Mini house campgrounds/compounds
“Glamping” locations
Wedding/Event Venues
Wineries with tasting rooms and some without
Man camps
Kids/Church camps
Churches
Industrial/Commercial operations (with or without customers/visitors)
Retail shopping center
Office/Warehouse facilities

Engineer

Are you an engineer or architect that provides land development design and permitting services but not familiar with the ins and outs of PWS permitting?

As you may be aware, the TCEQ PWS approval process is very regimented. Give us a call.

We would be happy to team/partner with you to provide full service to your client.

*Note, we can also conduct groundwater availability studies.

Developer

You have property you want to develop and have questions about how you are going to provide potable water, or the County is asking for a groundwater availability study.

Call us. We can help.

If they start talking in code using terms like WPAP or CZP, give us a call.

We do not typically do those projects, but we can point you in the right direction.

Licensed Operator

Are you a TCEQ licensed water operator?

We know operators may know how to operate a system, but may not be as familiar with the compliance and paperwork parts.

If you have questions about TCEQ compliance, give us call.

*Note, we do not provide licensed operators as a service.

OSSF/Septic Sanitarian, Designer, Installer

This is not news to you, but Counties should ask about the water supply source when you apply for an OSSF permit.

If the project should need to be a PWS, we would appreciate it if you contact us or pass our contact info to your client.

If they ask about a WPAP or CZP, give us a call. We do not typically do those projects, but we can point you in the right direction.

Scared

Has the TCEQ, City/County health official, or local groundwater conservation district contacted you about your water well or system (or lack of one)? Don’t be scared.

Agency officials are typically very nice and helpful, but… they do enforce the rules and they will not simply go away or forget about you. Don’t ignore them. Give us a call so we can help you get in compliance.

Depending on the situation, we might be able to determine that you should not be a PWS, thus removing any TCEQ involvement.

If you think you are not compliant with PWS rules and you have not been contacted by an agency (yet), give us a call and we can evaluate your system and make recommendations, if needed, to be compliant.

If you read through all of the scenarios above, hopefully you have picked up on one theme… call CSE with your PWS questions.

Frequently Asked Questions

How long does it take obtain PWS approval?
The PWS permitting process is not quick. Depending on your scenario, it can take 6-12 months to get through the PWS approval process. In addition to our time to prepare the submittals, the TCEQ review times are 100 days for exception requests and 60 days for plan reviews. Call us to discuss ways we can minimize the time frame. Hint: It requires for us to be involved early in the development process. (I'm envisioning one of those commercials that says "Don’t' wait, call now!".)

Can I use my existing well as a PWS well?
It depends. We can't guarantee the TCEQ will approve an old well, but we have had success in getting old wells approved for use. See "exception requests" below.

I've been operating my water system for 50 years, why do I need a PWS now?
This is an irrelevant fact. If you meet the definition of a PWS, you must obtain approval to operate as a PWS. You may continue to operate for another 50 years, or an agency may show up next week asking questions. TCEQ field investigators do simply drive to a location and start asking questions about their water supply.

Can I install a water softener or reverse-osmosis system as part of the PWS?
There are two answers here:

If the water quality does not meet TCEQ limits and you are adding a water softener, reverse-osmosis, or other water treatment technology in order to meet TCEQ requirements, these components would be part of the PWS system and require specific approval from the TCEQ.
If the water quality does meet TCEQ limits and you would like to add additional water treatment, we strongly recommend you install these on the "service" side. If you add water treatment as part of the main PWS system (prior to service connections), the water treatment falls under TCEQ PWS jurisdiction and must be approved by the TCEQ.

 
Do I have to hire someone to operate my PWS?
It depends. There are four classes (A-D) of licensed water operators. A small system may only require a D licensed operator. You may choose to train yourself or an employee to be a D licensed operator. You may visit this TCEQ webpage for more information. CSE does not provide licensed water operator services, but we can refer you to a few we work with.

What is an exception request?
As noted above, the PWS approval process is very regimented. If any part of the system deviates from the PWS rules, an exception request must be submitted for review and approval. Note in TCEQ lingo, obtaining an "exception request" is analogous to obtaining a "variance".
 
What if I am a PWS but no longer meet the definition of PWS? What do I do?
The TCEQ refers to this as "inactivation". See TCEQ's Regulatory Guidance document RG-550 for information on how to inactivate a system. Call us if you have questions after reviewing this document.

What is an Emergency Preparedness Plan (EPP) and do I need one?
First, it is important to note that you may need an EPP even if you are not a PWS. The short answer is, if you provide overnight accommodations to more than one customer, you need an EPP. See this TCEQ webpage for more information.